People v. Donald L. Garcia

CourtColorado Court of Appeals
DecidedJuly 28, 2022
Docket19CA1629
StatusPublished

This text of People v. Donald L. Garcia (People v. Donald L. Garcia) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Donald L. Garcia, (Colo. Ct. App. 2022).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY July 28, 2022

2022COA83

No. 19CA1629, People v. Garcia — Criminal Law — Disqualification of a Judge — Structural Error

A division of the court of appeals holds as a matter of first

impression that it is structural error for a statutorily disqualified

judge to preside over a case. COLORADO COURT OF APPEALS 2022COA83

Court of Appeals No. 19CA1629 Sagauche County District Court No. 17CR27 Honorable Amanda C. Hopkins, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Donald L. Garcia,

Defendant-Appellant.

JUDGMENT REVERSED AND CASE REMANDED WITH DIRECTIONS

Division I Opinion by JUDGE TOW Berger, J., concurs Dailey, J., concurs in part and dissents in part

Announced July 28, 2022

Philip J. Weiser, Attorney General, Brittany Limes Zehner, Assistant Solicitor General, Denver, Colorado, for Plaintiff-Appellee

Megan A. Ring, Colorado State Public Defender, Jacob B. McMahon, Deputy State Public Defender, Denver, Colorado, for Defendant-Appellant ¶1 Defendant, Donald L. Garcia, appeals the judgment of

conviction entered on a jury verdict finding him guilty of first degree

aggravated motor vehicle theft. This appeal requires us to consider

whether the fact that the judge who presided over the trial was

statutorily disqualified from doing so because of her prior

involvement in the case as counsel for defendant amounts to

structural error. We conclude that it does and therefore reverse the

judgment of conviction. Because we reject Garcia’s challenge to the

sufficiency of the evidence underlying the conviction, we remand for

a new trial before a different judge.

I. Factual Background

¶2 Garcia took his employer’s truck without his permission and

drove it off the road and across a drainage ditch, where it broke

down. The next morning, Garcia had a friend help him tow the

damaged truck back to his employer’s shop. The estimated repair

cost was $11,579.15.

¶3 Garcia was charged with first degree aggravated motor vehicle

theft on July 24, 2017. He was represented by Kate Mattern of the

State Public Defender’s Office. On April 17, 2018, Amanda

Hopkins, then a Deputy State Public Defender, appeared on behalf

1 of Garcia at a pretrial readiness conference at which he failed to

appear. As both parties concede, Judge Hopkins was appointed to

the district court bench on July 10, 2018. Judge Hopkins then

presided over the remainder of Garcia’s case, including all pretrial

hearings, the trial, and sentencing.

II. Disqualification of the Judge

A. Standard of Review and Applicable Law

¶4 We review de novo whether Judge Hopkins should have

disqualified herself. See People v. Julien, 47 P.3d 1194, 1197 (Colo.

2002).

¶5 “A judge of a court of record shall be disqualified to hear or try

a case if . . . [sh]e has been of counsel in the case.”

§ 16-6-201(1)(c), C.R.S. 2021. Judge Hopkins appeared as counsel

for Garcia at the pretrial readiness conference and was therefore

required to disqualify herself. See id. Her minimal level of

representation at the hearing does not change our conclusion.

Applying Julien to the defense context, “a judge must disqualify . . .

herself sua sponte . . . if facts exist tying the judge to . . . some role

in the [defense] of the case during the judge’s former employment.”

47 P.3d at 1198 (emphasis added). And if a judge “personally

2 participated in the [defense] of [the] case in any way,” she is

disqualified from serving as a judge in the case. See id. at 1200

(emphasis added). Because Judge Hopkins had “some role” in the

defense of the case and personally participated “in any way” in

Garcia’s defense, she erred by not disqualifying herself.1 See

§ 16-6-201(1)(c). Notably, neither party appears to assert that

Judge Hopkins’s appearance and minimal participation in the case

does not amount to her having “been of counsel” in the matter. See

id.

¶6 Further, we conclude that when a statutorily disqualified

judge presides over a case, it is structural error.

1 That being said, we intend no condemnation of Judge Hopkins. The record reflects that she was not Garcia’s assigned counsel and had filed no written entry of appearance. She appeared only at one court date, which was a pretrial readiness conference approximately one month before the then-scheduled trial date. It is not clear that Judge Hopkins ever met Garcia, as he failed to appear with her at the conference. And the minute order did not reflect Judge Hopkins’s appearance. Finally, although the transcript from the April hearing clearly shows Judge Hopkins’s appearance, there is no reason that, at that stage of the proceedings, either party or the court would have had the transcript prepared from a hearing at which Garcia failed to appear. Indeed, it appears the transcript was not prepared until the appellate record was being compiled. Thus, from this record, it is not surprising that Judge Hopkins would not have recognized her prior involvement in the case.

3 ¶7 In People v. Abu-Nantambu-El, 2019 CO 106, ¶ 39, our

supreme court held that when a potential juror who is statutorily

disqualified from serving pursuant to section 16-10-103(1), C.R.S.

2021, nevertheless serves on the jury, it is structural error. This is

so, the supreme court said, because such potential jurors “are

conclusively presumed by law to be biased.” Abu-Nantambu-El,

¶ 32.

¶8 In this respect, section 16-6-201 is analogous to section

16-10-103, in that it conclusively presumes that a judge who

previously served in the case as counsel is biased. No actual

enmity toward either side is required.2 We see no logical distinction

to be made between a statutorily disqualified juror and a statutorily

disqualified judge. See id. at ¶ 27 (noting that the Sixth

Amendment guarantees the “right to ‘an impartial adjudicator, be it

judge or jury’” (quoting Gray v. Mississippi, 481 U.S. 648, 668

(1987))).

2Nothing in the record suggests Judge Hopkins was actually biased against Garcia.

4 ¶9 Because Judge Hopkins was presumed by statute to be

biased, Garcia’s trial was “before a biased judge,” which is

structural error. See Hagos v. People, 2012 CO 63, ¶ 10.

B. Waiver

¶ 10 We also reject the People’s contention that Garcia waived this

claim.

¶ 11 Waiver is “the intentional relinquishment of a known right or

privilege.” People v. Rediger, 2018 CO 32, ¶ 39 (quoting Dep’t of

Health v. Donahue, 690 P.2d 243, 247 (Colo. 1984)). Just as

nothing in the record made Judge Hopkins’s prior involvement in

the case obvious to her, nothing made it obvious to Garcia or his

attorneys. Again, the minute order in the court file did not reflect

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Related

Gray v. Mississippi
481 U.S. 648 (Supreme Court, 1987)
People v. Gonzales
666 P.2d 123 (Supreme Court of Colorado, 1983)
Department of Health v. Donahue
690 P.2d 243 (Supreme Court of Colorado, 1984)
Clark v. People
232 P.3d 1287 (Supreme Court of Colorado, 2010)
People v. Julien
47 P.3d 1194 (Supreme Court of Colorado, 2002)
Stackhouse v. People
2015 CO 48 (Supreme Court of Colorado, 2015)
Martinez v. People
2015 CO 16 (Supreme Court of Colorado, 2015)
People v. Griego
2018 CO 5 (Supreme Court of Colorado, 2018)
People v. Rediger
2018 CO 32 (Supreme Court of Colorado, 2018)
Bondsteel v. People
2019 CO 26 (Supreme Court of Colorado, 2019)
Carousel Farms Metro. Dist. v. Woodcrest Homes, Inc.
2019 CO 51 (Supreme Court of Colorado, 2019)
Garcia v. People
2019 CO 64 (Supreme Court of Colorado, 2019)
v. Abu-Nantambu-El
2019 CO 106 (Supreme Court of Colorado, 2019)
v. Harrison
2020 CO 57 (Supreme Court of Colorado, 2020)
Peo in Interest of KDW
2020 COA 110 (Colorado Court of Appeals, 2020)
Dempsey v. People
117 P.3d 800 (Supreme Court of Colorado, 2005)
People v. Poindexter
2013 COA 93 (Colorado Court of Appeals, 2013)
People v. Dobler
2015 COA 25 (Colorado Court of Appeals, 2015)
Kerr v. Burns
42 Colo. 285 (Supreme Court of Colorado, 1908)
People v. Bennett
515 P.2d 466 (Supreme Court of Colorado, 1973)

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People v. Donald L. Garcia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-donald-l-garcia-coloctapp-2022.